In Re Mark Anthony Construction, Inc., Debtor. United States of America v. Ian Ledlin, Trustee

REINHARDT, Circuit Judge:

This case presents a single, straightforward question of statutory construction. The question is, however, a difficult one. We must, in effect, seek to divine the substantive import, if any, of a statute’s silence. In such a case reasonable arguments can often be made for either party’s position. Here, our decision is one shaped as much by the application of fundamental legal principles as by consideration of the previous cases which have examined the question.

The question we answer is framed easily enough: is the interest which accrues on taxes due after the filing…